Hoton respects and values the privacy of individuals with regards to personal data and strive to protect the same in accordance with the Data Privacy Act, DPA (“the Act”). As part of Hoton’s effort to protect your personal data, this Personal Data Privacy Notice is formulated in accordance with the Act. For the purpose of this Personal Data Privacy Notice, “Personal Data” shall have the meaning as described in the Act.

This Personal Data Privacy Notice applies to any person whose Personal Data is processed by Hoton including but not limited to Hoton’s clients, employees, and suppliers.

  1. This Personal Data Notice serves to inform you how your Personal Data is being processed by and /or on behalf of Hoton.
  2. The Personal Data proceeded by Hoton may include your name, contact details, date of birth, email address, and any other personal data required for the purpose set out in the paragraph below.
  3. Your Personal Data may be collected from various sources, including but not limited to information you have provided to Hoton, information from third parties and information in the public domain.


Hoton may collect, retain and use your Personal Data for among others the following purpose (“the Purpose”):

  1. Providing you with the services under any Hoton’s Businesses;
  2. Processing your application under any Hoton’s programmes;
  3. Providing you with ongoing information about events and programmes, Hoton’s products, services, special offers, new products, updates and promotions;
  4. Conducting research, develop and improve our events, programmes, products and services including but not limited to historical and statistical record keeping purpose;
  5. Discharging Hoton’s contractual obligations;
  6. Creating directories, databases or information technology system for Hoton internal and retail business operations;
  7. Resolving concerns and complaints;
  8. Recruitment purposes; and
  9. For any other purpose that is incidental or ancillary or in furtherance to Hoton’s internal and daily retail business operation.


Hoton may disclose your Personal Data to among others, the following parties as stated below for the Purpose:-

  1. Hoton’s parent company, subsidiaries, related and associated companies;
  2. Hoton’s licensees, co-organizers of events, business alliances, agents and service providers (including those located overseas);
  3. Any relevant authorities or bodies;
  4. Auditors, professional advisories;
  5. To such person pursuant to the requirements of any law, if such action is necessary to comply with the requirement of any law enforcement agency, a court order or legal process;
  6. The employees from Hoton’s parent company, subsidiaries, related and associated companies; and
  7. Any other person and/or organizations which Hoton may think fit.

Notwithstanding that any such persons may be outside the Philippines, your personal data is to be disclosed at the time of its collection or for any other purposes directly related to any of the above Purposes or where such disclosure is required or authorized by law or by the order of a court.


Efforts will be made to ensure that any Personal Data held by Hoton is kept up-to-date and is protected against any loss, misuse, modification, unauthorized or accidental access or disclosure, alteration or destruction.

Hoton may regularly reviewed the security measures in safe keeping your Personal Data and only authorized staff of Hoton who have been duly trained are allowed to handle the Personal Data.



Any Personal Data provided by you will be retained by Positive Living for a period that Hoton deems fit and necessary for the fulfillment of the Purposes or is required to satisfy legal regulatory, accounting requirements or to protect Hoton’s interest (“the Retention Period”).

Upon expiry of the Retention Period and/or after Hoton cease to process your Personal Data, Hoton will take all necessary action to permanently delete and destroy your Personal Data.



In accordance with the Act, you may request to access and/or modify and/or alter and/or update your Personal Data, subject to the following:

  1. Hoton may charge an administration fee for processing your request for access; and
  2. Hoton may refuse to comply with your request for access or correction in accordance with the Act.



  1. a) By providing Hoton your Personal Data, you hereby consent to the processing of your Personal Data in accordance with all of the foregoing (“the Consent”).
  2. b) Hoton may cease to process your Personal Data within a reasonable period upon receiving your written notice pertaining to the withdrawal of the Consent.
  3. c) Hoton’s website may contain links to other sites and pages. By activating a link, such as for example by clicking on the banner of an advertiser, you leave Hoton’s website and Hoton does not exercise control over any Personal Data or any other information you give to any other entity after you left Positive Living’s website.
  4. d) Any queries, comments, suggestions or information other than Personal Data sent or posted to the site, or any part of the site by visitors will be deemed voluntarily provided to Hoton on a non-confidential and nonproprietary basis. Hoton reserves the right to use, reproduce, disclose, transmit, publish, broadcast and/or post elsewhere such information freely, including passing it to any associated company, in connection with the development, manufacture and marketing of products and services and to meet customer needs.
  5. e) Hoton reserve the right at any time to add, change, update or modify this Personal Data Privacy Notice, simply by informing such change, update or modification via email, short message service, posting on the website and such other notifications as Hoton may deemed fit. Any such change, update or modification will be effective immediately upon posting on the website.
  6. f) Please note that in the event your Personal Data is not sufficiently provided, or is not satisfactory to Hoton, your application or request to Hoton for any of the Purposes may not be accepted.
  7. g) Hoton reserves the right to change these terms and conditions at any time without prior notice. In the event that any changes are made, the revised terms and conditions should be sent to you via email immediately.